NASA RFP Allows for Independent Accounting System Review: Begin the Process Now

Very recently, NASA released a draft Request for Proposal (RFP) for Space Exploration Networks Services and Evolution (SENSE). Section L of the draft RFP requires offerors to provide evidence of an adequate accounting system for accumulating and reporting incurred costs. It also requires significant subcontractors to “provide the same supporting information that is requested from the Prime Offeror.”

The RFP suggests the evidence of an approved accounting system could come from a cognizant administrative office. NASA also recognizes that all well-qualified offerors and their teaming partners may not have had the opportunity to have their accounting system audited by the government. Consistent with an emerging trend throughout the government, NASA is allowing “any independent audit and system approvals, as well as documented system ability, to segregate and accrue costs by contracts.”

If you believe your company or significant teaming partner has already implemented an acceptable accounting system as per Federal Acquisition Regulation (FAR) 16.301-3(a)(3), Cost-Reimbursement Contracts-Limitation, but have not yet had the government approve it, a thorough accounting system audit should be performed based on the criteria outlined in Defense FAR Supplement (DFARS) 252.242-7006, Accounting System Administration. DFARS 252.242-7006 generally represents what all federal agencies require in such systems. It is crucial to get a head start on this process and avoid waiting until the final RFP is released given time is limited.